Who Are We?
My Broadband Switch (mybroadbandswitch.co.uk) is a trading name of Interrog8 Ltd.
Interrog8 LTD are a UK consumer Data Processor. This means that we gather information about people from different data sources called Data Contributors. The data includes loan applications, competitions entries, newsletter subscriptions and public databases such as the Edited Electoral Roll, the Land Registry, and the Energy Performance database. We combine this information to create a Single Customer view so we can provide your information to other companies who want to contact you about their products and services. These other companies are called Third Party Controllers and we share your information with them.
Company Registration Information
Interrog8 Ltd is registered in England and Wales (registered number 10886132). Our registered office is at Unit 1, Flex Space, Jessop Close, Newark, NG24 2TT.
ICO Registration No: ZA274506
Our Data Collection Practices
Interrog8 Ltd is a leader in the marketing services industry, so we adopt and implement best practices and diligently seek to follow all laws governing the acquisition, compilation, and distribution of consumer data. These practices include careful screening of data sources, ongoing internal audits, and appropriate consumer notice and choice.
Consent and Legitimate Interests
Your data must be processed by us using one of the valid legal bases set out in the regulations. The two we utilise are.
This is where you consent for contact by a specific organisation by communication channels agreed by you, for specific reasons, which in the context of our processing will be for marketing purposes. When we ask for your consent for a specific organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone.
You can of course withdraw your consent at any time, and we will describe later in this policy.
As a direct marketing business, we process personal data for commercial benefit. We require an appropriate legal basis to do this. In considering the most appropriate legal basis, Interrog8 conducted Legitimate Interest Assessments. These are evaluations of each type of data processing activity to ensure we have balanced the need for processing against the rights of the individual to ensure minimal privacy impact.
Your data will be processed in pursuance of legitimate interests, this includes using your data for postal and telephone by ourselves or partners in relation to products or services we believe will be of interest to you based on the information you have provided.
For all types of processing activities, we apply various measures to protect your privacy rights. As with all data processing you can object as detailed below.
All Lawful Bases for Processing
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Why do we process your information?
We process your information to share with Broadband Providers to create more value for money, get better results and create benefits for you and your family.
Data Retention and How We Retain Data
In accordance with the GDPR, personal data shall be kept for no longer than is necessary for the purposes for which it is being processed.
Interrog8’s systems store personal data therefore all reasonable precautions shall be taken to ensure that appropriate confidentiality and control procedures are in place. We take the security of your data and the accessibility to our systems very seriously, with an emphasis on physical security, network, and application security.
Why do we share your information with Third Party Controllers?
We only share your information if you have given explicit consent. This means that you have made a positive action to opt-in and agree to contact from one of our broadband providers.
How do we process your information?
Your information is shared with one of our broadband providers to contact you regarding the quote requested on the channels provided.
What “Your Rights” are
Your Individual Rights in respect of personal data that we hold as a controller are:
A: Right to access – You have the right to request details of the personal data we have about you.
C: Right to Rectification – You have the right to ask us to rectify the information held on you if it is inaccurate or incorrect.
D: Right to erasure – This is also known as “the right to be forgotten”. This gives you the right, in certain circumstances, to request your information to be removed/erased.
E: Right to Restrict processing – You have the right, in certain circumstances, to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are repeated in the future.
F: Right to portable data – This gives you the right, in certain circumstances, to ask for your information to be transferred to another business.
G: Right to Object – You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights, and freedoms; or the processing is in relation to a legal claim.
H: Rights related to automated decision-making including profiling – To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
I: Right to withdraw consent at any time – You have the right to withdraw your consent to us sending marketing communications to you at any time.
J: Right to lodge a complaint – If we cannot deal with your complaint to your satisfaction, you have the right to complain to a relevant supervisory authority.
The Information Commissioners Office – https://ico.org.uk/concerns/
How do you withdraw your consent for marketing?
Withdrawing consent is simple. You can email email@example.com with your request to withdraw your consent. Please include your First Name, Surname, [Mobile, Landline or Email] and Postcode so we can identify you and remove your information from the database.
It can take up to 28 days to remove your information from all Third-Party Controllers.
If you continue to receive marketing message after 28 days after your request to withdraw your consent, please contact us directly.
Alternatively, you can call us on 0203 950 2982. Our office opening hours are Monday to Friday between 9:00am and 5:00pm.
Please be aware that a Subject Access Request can only be accepted in writing and we cannot give out personal information over the telephone without first taking the required steps to satisfy our obligations to GDPR, the ICO and the Data Protection Act.
You may withdraw your consent at any time.
More useful information to manage your marketing preferences below:
Postal Marketing – You can opt out of postal marketing by registering with the Mail Preference Service (MPS) This is an industry wide service that is administered by the Direct Marketing Association and recognised by the Information Commissioner.
Telephone Marketing – You can opt out of all telemarketing activity by registering their details with the Telephone Preference Service (TPS) The TPS is similar to the MPS but is administered by the Information Commissioner.
Email Marketing – Unlike Postal or Telephone channels, there is no industry-wide service to opt out of email marketing. Therefore, consumers should always review privacy policies and marketing opt-in check boxes when registering for services or purchasing products online. Where unwanted email marketing is received, consumers should unsubscribe or use spam filters to prevent future communications.
Online Advertising – Marketing data is widely used to inform the advertising that is displayed when browsing online. Whilst digital marketers generally do not know the identity of the individual viewing a page, they are able to understand their likely characteristics based on their browsing behaviour or location in order to display a more relevant advert.
Cookies– are small files used by websites to recognise returning visitors and tailor content or advertising more effectively. Declining cookies when visiting websites will prevent those sites from displaying targeted advertising, whilst all modern browsers have a setting to clear cookies, which will delete all cookie data stored from previous website visits.
cookies used for advertising do not generally work on mobile devices, however, advertisers can still recognise returning visitors both when browsing online and when using apps through the use of an ‘Advertising ID’. The Advertising ID is created by the mobile device, but can be reset at any time, thereby deleting all data held against it.
What information do we Collect?
Who do we share your information with?
We may share your information with any of the companies/sectors in the below list. Your data may also be shared with future companies promoting the Products and Services listed
How can you access the information we hold about you?
You must make a Subject Access Request (SAR) to access information that we hold about you.
For us to process your request it is our responsibility to identify you and be satisfied that you are the individual whom the data relates to. You cannot make a SAR on behalf of someone else unless you have the required written authority or demonstrable Power of Attorney.
The simplest way to make a SAR is to email us at firstname.lastname@example.org or alternatively you can write to us at Data Protection Officer, Interrog8 Ltd, Unit 1 Flex Space, Jessop Close, Newark, NG24 2TT.
With any SAR you must include the following information:
When have received the information outlined above we will contact you to process your SAR.
For more information and advice on what you are entitled to then please carefully read the information from the UK Supervisory Authority here ico.org.uk/for-the-public/personal-information
Our security measures.
We are aware of the importance of safeguarding the information under our control and endeavour to take all reasonable steps to protect it. All data collected through from our data contributors is stored on secure servers, and we have stringent security and confidentiality procedures covering the storage and disclosure of such information in accordance with the Data Protection Act 1998. Any data shared is submitted only via secure https sharing platform utilising single user authentication. This platform has full track and trace ability to log when, where and by whom the data was accessed by.
However, providing information and transacting over the internet has inherent security risks, and we cannot be held responsible for any breach of security which is outside our reasonable control or not due to our negligence or wilful default.
Last Updated: August 5th, 2021
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